When you use our services (“Services”) by accessing our website at https://smartframe.io/ (the “Website”), interact with images that use our SmartFrame Technology (“SmartFrame Images”), browse websites that contain SmartFrame Images, communicate with us via our online, telephone or social media channels, or submit your data anywhere this Policy is posted, this Policy will apply to you.
So we can remain transparent about how we use your personal data, when there are significant updates to the Policy we will notify you if we have a means of contacting you, but you are invited to continually revisit the policy to check for updates.
This Policy was last updated on 31st October 2020.
References to (“we”, “our”, or “us”) are to SmartFrame Technologies Limited, a company registered in England and Wales. We are the Data Controller and determine the purpose and manner in which your personal data is used.
Our Website, SmartFrame Images or the websites hosting our SmartFrame Images may contain links to other websites operated by other organisations. These third-party organisations will have their own privacy policies which you should read carefully before providing any of your personal data as we do not accept any responsibility or liability for the websites of other organisations.
Upon subscribing to our Services and later accessing your account, you may provide us with:
- Your personal details, including your name, title, postal and billing addresses, email addresses, phone numbers and date of birth
- Your debit or credit card details, bank details and other payment information
- Your account login details, such as your username and password
When you browse our Website or a website with a SmartFrame Image, or interact with our SmartFrame Images, we may collect:
- Purchase Information (e.g., the plan you have subscribed to, when and where you bought it and how you paid for it)
- Information about your online browsing behaviour on our Website, information about your interactions with our SmartFrame Images, and information about your activities when you click on an advertisement that we display with one of our SmartFrame Images – this information will let us know such things as the amount of time you spend browsing our Website or engaging with our SmartFrame Images and whether you have viewed one of our adverts
- Information (including the make, model and operating system, IP address and browser type) about any devices you have used to access our Services or interact with our SmartFrame Images
When you obtain a SmartFrame Image from one of our partners, we may collect:
- Your email address
When we communicate with each other or you sign up for our newsletters or take part in our surveys about our Services, we may collect:
- Personal data you provide about yourself anytime you contact us about our Services, (for example, your name, username and contact details) including by phone, email or post or when you speak with us through social media
- Details of the emails and other digital communications we send to you that you open, including any links in them that you click on
- Your responses to customer surveys and questionnaires
We cannot guarantee the security of any personal data that you transfer over the internet to us; however, we do take appropriate technical and organisational measures to safeguard your personal data. We use technical safeguards such as firewalls and data encryption, and we employ access controls to our buildings and files to keep your data safe.
- We protect the security of your information while it is being transmitted by encrypting it using Secure Sockets Layer (SSL).
- We enforce physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal data. We will ask for proof of identity before we share your personal data with you.
- We will reveal only the last four digits of your credit card number when confirming an order.
The personal data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (“EEA“). It may also be processed by companies operating outside the EEA who work for us or for one of our service providers. If we do this we ensure that your privacy rights are respected in line with this Policy. The most common way we do this is to put in place a specific type of contract, a copy of this type of contract can be found here
We set out below how we use your data and the lawful basis for doing so. References to our “legitimate interests” are to those interests we have in running our business, developing our products and services, delivering and improving our products and services, and ensuring an excellent customer experience in a way which may reasonably be expected and don’t infringe on your rights and freedoms.
|Our use of your personal data||Explanation of this use||Reason for using your personal data in this manner||Legal Basis|
|To make our product and services available to you||When you subscribe to our Services either directly or through one of our partners, you establish an account with us that you access to make use of our Services.||We need to process your payment details, name, email address, password, and queries you submit to us so that we can establish your account; take payment for our services; provide you with the services; update you on any changes to the services; and help you with any requests you may have about your subscription.||We rely on Contractual necessity to process the data required to enter into a contract with you.
We rely on Legitimate Interests for our activities related to the ongoing use of your data for the other purposes set out in this section.
|Our SmartFrame technology displaying SmartFrame Images may be enabled to display adverts that are both relevant to the SmartFrame Image and the location where the SmartFrame image is being viewed. We use information (including the IP address, make, model, operating system, and browser type) about the devices that access the websites where the SmartFrame Images are displayed in order to serve these adverts.
We don’t serve adverts that are based on your individual use or interaction with a SmartFrame Image or are targeted at you AND we don’t create any profiles of you.
We store and obtain additional information by using cookies on the websites that have our SmartFrame Images.
|We use IP addresses to determine the location where the SmartFrame Images is being displayed so that we only serve adverts that are relevant to that location. We only maintain the location information that forms part of the IP address and the IP address is anonymised so it cannot be used to identify you or anyone who may have used your device.
We use the other information we have collected about your device to ensure that the adverts and the SmartFrame Image are optimised with the correct technical dimensions to be viewed on your device.
|We carry out market research, gain customer insights, improve our information technology systems (including security), improve our SmartFrame Images and our subscription offers||We use your personal data as it provides an effective means to develop and improve our content, services, information technology systems, know-how and the way we communicate with you.||Legitimate Interest|
|We monitor how our Services and SmartFrame Images are used to detect and prevent fraud, other crimes and the misuse of our Services and SmartFrame technology.||This helps us to ensure that you can safely use our Services and that our SmartFrame Images can deliver adverts that are responsive to legitimate user interactions.||Legitimate Interest|
|Personalise your user experience||We use your online browsing behaviour on our Website to help us better understand your interests and provide you with personalised offers and services.||Looking at your browsing behaviour and purchases allows us to personalise our offers and services for you. This helps us meet your needs as a customer.||Legitimate Interests|
|We use your marketing preferences to tailor our marketing communications to your interests. This means we can provide you with relevant marketing communications (including by text or email), relating to our Services. We may also measure the effectiveness of our marketing communications.||Our knowledge of your preferences and ability to measure your responses to marketing communications relating to the services you have subscribed to, allows us to offer you products and services that better meet your needs as a customer.
You can change your marketing choices, both when you set up your account with us, and at any time after that.
You can object to receiving marketing information from us at anytime and where we send you marketing information based on your consent – you may withdraw your consent
|It is in our Legitimate Interests to provide marketing communications about our own Services for all other marketing communications we rely on your Consent|
|Contact and interact with you||You will always have the opportunity to contact us via our Website or other channels we make available to you and we may communicate with you about the Services that you have subscribed to.||Using your personal data in this manner ensures we can respond to your queries and can communicate the most up to date information about the services that you have subscribed to.||Legitimate Interests|
|We will on occasion prepare newsletters with information about our products and services.||Where you have elected to receive our newsletters, we will use your personal data to send the newsletter to you..||Legitimate interest|
|From time to time we invite our customers to take part in customer surveys, questionnaires and other market research activities carried out by us and by other organisations on our behalf.||We use your personal data to conduct and manage these surveys, questionnaires and research activities so that we may improve our Services. You do not have to take part in these activities. You will always be able to tell us that you do not want us to contact you for these activities and this will not affect your ability to use our Services||Legitimate Interest|
|Where SmartFrame Images are available for you to embed on your own website, we may make the embed code available to you via email.||We require your email to send you the embed code for the SmartFrame Image that you may request. We may also use and share this email address with our partners for their marketing purposes (with your consent)||Legitimate Interest|
We work with Service Providers that carry out certain functions on our behalf. These include, for example, companies that help us with customer care services, network and technology services, storing and combining data, processing payments and managing subscriptions, sourcing adverts that are relevant to the SmartFrame Images and the location where they are viewed, evaluating whether the websites where we serve adverts are appropriate for the advertised brand, detecting whether visitors to the websites where we have SmartFrame Images are real or are automated bots. We only share personal data that enable our Service Providers to provide their services.
Sharing personal data with other organisations
We may share personal data with other organisations in the following circumstances:
- If we are engaged by a partner to provide our SmartFrame technology as part of their offering and we need to work together to deliver a service to you, respond to your queries, or you have given us your consent for such sharing;
- if the law or a public authority says we must share the personal data;
- if we need to share personal data in order to establish, exercise or defend our legal rights (this includes providing personal data to others for the purposes of preventing fraud); or
- to an organisation we sell or transfer (or enter into negotiations to sell or transfer) any of our businesses or any of our rights or obligations under any agreement we may have with you. If the transfer or sale goes ahead, the organisation receiving your personal data can use your personal data in the same way as us.
Your personal data won’t be kept longer than necessary, giving due regard to: initial purpose of collection; age of data; any legal/regulatory reason for us to keep it; and whether needed to protect you or us. If requested, we will readily make information available about our data retention policy.
Below, we set out the rights you have under the GDPR in relation to your personal data. Should you wish to exercise any of these rights, please write to us using the information provided under the “How to contact us” section of this Policy.
Subject Access Rights —You have a right to see the personal data we hold about you and the circumstances of our processing activities.
Right to have inaccurate information corrected — if you believe we hold inaccurate or missing information, please let us know and we will correct it.
Right to object to our use of your personal data — We will consider your objection to our use of your personal data. If on balance, your rights outweigh our interests in using your personal data, then we will at your request either restrict our use of it or delete it.
Right to object to direct marketing – where we engage in direct marketing activities (after getting your consent), if you make such an objection, we will stop using your personal data for direct marketing purposes.
Right to restrict our use of your personal data — you can restrict our use of your personal data, if you have successfully made a general objection, you are challenging the accuracy of the personal data we hold, or we have used your personal data unlawfully — but you do not want us to delete it.
Right to have your personal data deleted — you can have us delete your personal data when: we no longer need to keep your personal data; you have successfully made a general objection; you have withdrawn your consent to us using your personal data (where we have relied on consent as the lawful basis for doing so); or we have unlawfully processed your personal data
Right to complain to the data protection regulator
We’d like the chance to resolve any complaints you have, however you also have the right to complain to the data protection regulator in the UK or EEA country where you receive our Services or access our product, about our use of your personal data. In the UK, the data protection regulator is the ICO and their website is at https://ico.org.uk.
We do not knowingly collect personal data from children. Should we become aware that we are processing the personal data of any children, we will delete such personal data as soon as possible.
If you are a California Resident, you will have additional rights under the California Consumer Protection Act.
We only share anonymised data for non-targeted ad revenue
As described in the Sharing personal data with Service Providers and other Organisations section of this Policy, we do share personal data with our Service Providers who source relevant but non-targeted adverts that are required to enable the ad functionality of our SmartFrame technology. In relation to any adverts that we source, we only share anonymised IP addresses and only the location information where a SmartFrame Image is being viewed is transmitted. As this information is shared in an anonymised format it cannot be used to identify an individual.
We are not selling your personal information
The information we share with our service providers who source our adverts is necessary for our business purpose of having our SmartFrame technology being fully enabled for a SmartFrame Image. We only share information for this business purpose to the service providers that source our adverts and we neither sell or use the information beyond what is necessary for this purpose.
This Policy complements and does not replace national data protection laws. Any applicable national data protection law will supersede this Policy where such law imposes stronger requirements and this policy shall apply where there are no national data protection laws.